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AML/CTF obligations for Dealers in Precious Metals and Stones

Designated services offered by

Dealers in Precious Metals and Stones

Under the AML/CTF Amendment Bill 2024, specific services provided by dealers in precious metals and stones will be designated as covered activities and will be subject to AML/CTF obligations. These services include:

Buying or Selling Precious Metals and Stones for Cash

Transactions involving gold, silver, diamonds, and other high-value assets paid for in cash.

Facilitating High-Value Transactions

Acting as intermediaries in large-scale deals that involve the transfer of precious metals and stones.

Storing or Transporting Precious Metals and Stones

Providing secure storage or transportation services, which can be misused for illicit asset movement.

Operating Precious Metals Refineries

Processing raw gold and other metals, which can be exploited to integrate illicitly sourced materials into the legitimate supply chain.

Engaging in Wholesale or Retail Trade of Precious Metals and Stones

Selling high-value goods that can be used for laundering illicit funds.

Brokering Transactions for Precious Metals and Stones

Facilitating deals between buyers and sellers, creating opportunities for anonymity in high-risk transactions.

Providing Loans or Credit Secured Against Precious Metals and Stones

Allowing criminals to convert illicit assets into legitimate funds through pawnshops and secured lending.

If your business provides any of these services, it will be subject to AML/CTF obligations.

Why are Dealers in Precious Metals and Stones

Subject to AML/CTF laws?

Dealers in precious metals and stones are subject to AML/CTF laws because their products are high-value, portable, and easily tradable, making them attractive for money laundering and illicit financial activities. Criminals may exploit these businesses by:

Using Cash Transactions to Avoid Financial Oversight

Buying precious metals and stones with illicit cash to convert illegal funds into legitimate assets.

Smuggling and Cross-Border Transfers and Transactions

Moving high-value, easily transportable assets across borders to bypass traditional banking controls.

Refining Illicitly-Sourced Gold and Precious Metals

Laundering proceeds of crime by melting and refining raw materials into new, untraceable forms.

Using Precious Stones and Metals as Collateral for Loans

Converting illicit funds into loans secured by high-value items, effectively cleaning the money.

Structuring Transactions to Avoid Detection

Splitting high-value purchases into smaller transactions to evade reporting thresholds.

Engaging in Trade-Based Money Laundering

Over- or under-invoicing the value of precious metals and stones in international trade to disguise illicit funds.

Repeated Sale and Resale of High-Value Assets

Repeatedly buying and selling items to integrate criminal proceeds into the legitimate market.

Lack of Transparency in Ownership and Transactions

The use of intermediaries and private sales makes it difficult to trace buyers and sellers.

By imposing AML/CTF obligations, supervisors are aiming to prevent dealers in precious metals and stones from being exploited as unwitting enablers of financial crime.

Money Laundering and Terrorism Financing (ML/TF)

Risks in the Dealers in Precious Metals and Stones sector

Dealers in precious metals and stones face significant ML/TF risks, including:

  • High-Value, Portable Assets – Precious metals and stones can be easily transported and traded, making them ideal for laundering illicit funds across borders
  • Use of Cash Transactions – Large cash purchases allow criminals to convert illicit funds into valuable assets without detection
  • Smuggling and Cross-Border Transfers – Criminals exploit weaknesses in customs controls to move precious metals and stones internationally, avoiding financial scrutiny
  • Refining Illicit Gold and Precious Metals – Dirty gold and other illegally sourced metals can be melted down and refined, erasing their criminal origins
  • Trade-Based Money Laundering (TBML) – Over- or under-invoicing the value of transactions allows criminals to manipulate the movement of illicit funds
  • Use of Intermediaries and Front Companies – Criminals may use third parties or shell companies to conduct transactions, concealing their identity and the true source of funds
  • Collusion with Illicit Supply Chains – Stolen or illegally mined precious metals and stones can be introduced into the legal market, disguising their origins
  • Multiple Resale Transactions – Repeated buying and selling of assets creates layers that obscure the money trail
  • Lack of Customer Due Diligence (CDD) – Private sales and unregulated transactions make it difficult to verify the identity of buyers and sellers
  • Use as a Store of Value for Criminal Proceeds – Precious metals and stones can be held indefinitely or used as collateral for loans, allowing criminals to retain wealth while avoiding detection.

To comply with the AML/CTF Act by 1 July 2026, dealers in precious metals and stones must conduct a thorough ML/TF risk assessment to identify, mitigate, and manage risks effectively.

For more information on the ML/TF risks faced by dealers in precious metals and stones, click here.

AML/CTF

Programs and Policies

In addition to designing, executing and maintaining a money laundering, terrorism financing and proliferation financing (ML/TF/PF) risk assessment reporting entities are expected to implement AML/CTF policies that are both appropriate and proportionate to the identified risks, in order to mitigate and manage these risks.

The diagram below outlines at a high-level the other key pillars of an AML/CTF Program:

In addition to designing, executing and maintaining a money laundering, terrorism financing and proliferation financing (ML/TF/PF) risk assessment reporting entities are expected to implement AML/CTF policies that are both appropriate and proportionate to the identified risks, in order to mitigate and manage these risks.

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HOW Dealers in Precious Metals and Stones CAN MEET THEIR

AML/CTF Obligations

To meet AML/CTF obligations, dealers in precious metals and stones must:

Conduct an Enterprise-Wide ML/TF/PF Risk Assessment considering factors such as customer risks, product and services risks, channel risks, transaction risks, and geographical risks

Develop and maintain AML/CTF policies, outlining compliance measures and risk mitigation strategies

Conduct Customer Due Diligence (CDD), verifying customer identities before transactions. High-risk clients require Enhanced Due Diligence (EDD)

Conduct Know Your Employee (KYE) checks, by performing employment and criminal history background checks and enhanced controls for employees occupying key risk roles

Provide initial and ongoing AML/CTF training to employees (and contractors) to ensure they understand their obligations and can identify ML/TF risks and escalate as appropriate

Monitor transactions to detect unusual activity or suspicious patterns indicative of money laundering or terrorism financing (or have oversight of financial institutions conducting on their behalf)

Conduct regulatory reporting to AUSTRAC where required

Conduct an independent review of AML/CTF policies at least every 3-years

Maintain records of all customer due diligence, reports, and related correspondence for at least seven years

These measures are critical to safeguarding the dealers in precious metals and stones sector from criminal exploitation and ensuring compliance with Australia’s strengthened AML/CTF framework.

Note: The AML/CTF Rules are being developed by AUSTRAC and are under a consultation process and are subject to change.

Anti-Money Laundering 101_ What do Australian Dealers in Precious Metals and Stones need to know about the AML_CTF Amendment Act 2024 and how can they start to prepare to comply

Anti-Money Laundering 101: What do Australian Dealers in Precious Metals and Stones need to know about the AML/CTF Amendment Act 2024 and how can they start to prepare to comply?

AML/CTF compliance for precious metals dealers.

How do organised criminals exploit dealers in precious metals and stones to launder the proceeds of their crimes and what can you do to prevent this happening in your business

How do organised criminals exploit dealers in precious metals and stones to launder the proceeds of their crimes and what can you do to prevent this happening in your business?

Learn how criminals exploit precious metals dealers for money laundering.

Case Studies_ How organised criminals have exploited dealers in precious metals and stones to launder the proceeds of their crimes and how you can prevent this happening in your business

Case Studies: How organised criminals have exploited dealers in precious metals and stones to launder the proceeds of their crimes and how you can prevent this happening in your business

Read about criminals exploiting precious metals dealers.

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